Finding Text
Finding 2025-003 - Significant Deficiency: Special Tests and Provisions - Compliance and Control Finding Student Financial Aid Cluster Federal Agency: U.S. Department of Education Federal Award Number: 84.268, 84.007, 84.063, 84.379 Criteria: Under federal Return to Title IV (R2T4) requirements, an institution must determine the earned and unearned portions of the Title IV aid based on the amount of time a student was scheduled to be in attendance as of the date the student ceased attendance. For students enrolled in modular programs, the R2T4 calculation must use the number of days between the start of the first module and the originally scheduled end date of the last module the student was expected to attend, when determining the scheduled days in the period when the student receives direct loans and no R2T4 Freeze date is utilized by the institution. Condition: In our nonstatistical sample of 20 students tested for R2T4 compliance requirements, we noted 5 students who were enrolled in modular programs, who were awarded and received Federal Direct Loans, and had scheduled enrollment in both the 1st 8-week session and 2nd 8-week session of a semester in the year ended June 30, 2025 where the University improperly used the end date of the 1st 8-week session as the scheduled end date in the R2T4 calculation as opposed to using the end date of the 2nd 8-week session as the scheduled end date in the R2T4 calculation. Cause: The University did not have adequate controls to ensure that the R2T4 calculations for students enrolled in modular programs incorporated the correct scheduled end date for all modules the student was expected to attend. Effect: As a result of using the improper scheduled end date, the University’s calculation of the amount of aid earned by the students exceeded the amount of aid earned that we recalculated by $6,308. This resulted in the University and the students being able to keep $6,308 of a combination of Pell grant, direct subsidized loans, and direct unsubsidized loans that should have been returned to the U.S. Department of Education. Questioned Costs: We identified questioned costs in our sample of $6,308. The amount of estimated likely questioned costs based on an extrapolating the error identified to the remaining population of withdrawals that took place in a 1st 8-week session totaled $35,384. Context: We noted the error identified for 1 student in the Fall 2024 semester and for 4 students in the Spring 2025 semester. Identification As A Repeat Finding: Not a repeat finding. Recommendation: We recommend the University strengthen internal controls over R2T4 calculations for modular programs by revising R2T4 procedures to require verification of all modules the student was scheduled to attend at the time of withdrawal, implementing system prompts or checklists to ensure staff used the scheduled end date of the last module the student was expected to attend when determining the number of scheduled days in the R2T4 calculation, and performing periodic quality-control reviews of R2T4 files involving modular enrollment to ensure accurate determination of scheduled days. We recommend that the University perform recalculations of its modular returns for students who withdrew from a 1st 8-week session and were originally enrolled in both a 1st 8-week session and 2nd 8-week session in the year ended June 30, 2025, update its scheduled end dates utilized the R2T4 calculations, and return any additional unearned funds based on the revised calculations. Views Of Responsible Officials: Management concurs with the finding. The University is updating its written R2T4 procedures to ensure the appropriate scheduled end date is consistently used for students enrolled in modular programs. System enhancements and new workflow controls will be implemented to require documentation of all modules a student was scheduled to attend. The University will work to recalculate returns for students who withdrew from modules as recommended. Anticipated Completion Date: March 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services